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Re: TII post# 307678

Wednesday, 07/22/2015 5:28:56 PM

Wednesday, July 22, 2015 5:28:56 PM

Post# of 795947
v. ) No. 13-465C ) (Judge Sweeney) ) IN THE UNITED STATES COURT OF FEDERAL CLAIMS FAIRHOLME FUNDS, INC., et al., ) ) Plaintiffs, ) THE UNITED STATES, ) ) Defendant. ) PLAINTIFFS’ UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME TO FILE A PROPOSED AMENDED PROTECTIVE ORDER Pursuant to RCFC 6.1(a), Plaintiffs respectfully move for an enlargement of time of 5 days to file a proposed Amended Protective Order. On July 10, 2015, this Court issued an order in Cacciapalle v. United States, No. 13-466 (Fed. Cl.), and related cases specifying that counsel for the parties in such cases, along with Fairholme’s counsel, should confer on proposed changes to the July 16, 2014 Protective Order (Doc. 73) entered in this case and submit a proposed Amended Protective Order by today, July 22, 2015. Counsel have been diligently conferring on possible changes, but there remain issues to resolve before the parties can propose an Amended Protective Order to this Court. Accordingly, Plaintiffs respectfully request a 5-day extension, such that the proposed Amended Protective Order will be due on July 27, 2015. In accordance with RCFC 6.1(b), Plaintiffs have consulted with opposing counsel, and the Government does not oppose this motion. Date: July 22, 2015 Of counsel: Vincent J. Colatriano David H. Thompson Peter A. Patterson Brian W. Barnes Respectfully submitted, s/ Charles J. Cooper Charles J. Cooper Counsel of Record COOPER & KIRK, PLLC 1523 New Hampshire Avenue, N.W. Washington, D.C. 20036